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SEC Reopens Comment Period on Proposed Data Breach Disclosure and Cybersecurity Governance Rules

By Kristin Bryan & James Brennan on October 10, 2022
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Last Friday, the Securities and Exchange Commission reopened the comment period on eleven of its pending rulemakings because of a technological error that caused the SEC not to receive all of the comments submitted during the original comment period.  One of the eleven proposals affected by the reopening is the SEC’s proposal from March of this year that would require all public companies to disclose (1) material cybersecurity incidents and (2) their cybersecurity risk management, strategy, and governance procedures.  The current proposal, which has received dozens of comments already, would, among other things, require companies to file a public disclosure form when the company suffers a “material cybersecurity incident” within four business days after the company has determined the incident is material.

Anyone interested in submitting comments to the proposed rule will have at least 14 more days to submit comments to the SEC via the online form (file number S7-09-22), email, or regular mail.  The SEC has advised that anyone who previously submitted comments between June 2021 and August 2022 “check the relevant comment file on SEC.gov to determine whether their comment was received.”  CPW will be monitoring the submissions on the proposal for significant comments and be here to keep you in the loop.

Photo of Kristin Bryan Kristin Bryan

Kristin Bryan is a data privacy and cybersecurity litigator experienced in the resolution of complex disputes.

Kristin has deep expertise defending clients in federal class action and multidistrict litigations concerning allegations that their practices violated federal and state privacy laws. This includes in…

Kristin Bryan is a data privacy and cybersecurity litigator experienced in the resolution of complex disputes.

Kristin has deep expertise defending clients in federal class action and multidistrict litigations concerning allegations that their practices violated federal and state privacy laws. This includes in the context of data breach and incident response litigation. As a natural extension of her experience litigating data privacy disputes, Kristin also provides practical, business-oriented privacy advice to a wide range of clients and has represented them in government investigations regarding their privacy practices.

Kristin is CIPP/US certified and routinely publishes and speaks on cutting-edge developments in data privacy and cybersecurity litigation. Kristin is currently the co-chair of the International Association of Privacy Professional (IAPP)’s KnowledgeNet Chapter for Cleveland and on the IAPP’s Privacy Bar Advisory Board. She is a 2020-21 Vice Chair of the ABA TIPS Cybersecurity and Data Privacy Committee and managing editor of Squire Patton Boggs’ data privacy blog Consumer Privacy World.

Prior to joining the firm, Kristin worked at an international law firm in New York, specializing in Data Strategy & Security.

View full website bio.

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Photo of James Brennan James Brennan
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  • Posted in:
    Privacy & Data Security
  • Blog:
    Privacy World
  • Organization:
    Squire Patton Boggs
  • Article: View Original Source

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